EPA-450/3-74-028-a
May 1973
AIR POLLUTION/LAND USE
PLANNING PROJECT
VOLUME I.
SELECTED LAND USE
CONTROL POLICIES FOR
AIR QUALITY MANAGEMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Water Programs
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA-450/3-74-028-a
AIR POLLUTION/LAND USE
PLANNING PROJECT
VOLUME I. SELECTED LAND USE
CONTROL POLICIES FOR
AIR QUALITY MANAGEMENT
by
A. S. Kennedy, K. G. Croke,
T. E. Baldwin, andR. L. Reisenweber
Center for Environmental Studies
Argonne National Laboratory
9700 South Cass Avenue
Argonne, Illinois 60439
Interagency Agreement No. EPA~IAG-0159(D)
EPA Project Officers:
John Robson and David Sanchez
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Water Programs
Office of Air Quality Planning and Standards
Research Triangle Park, N. C. 27711
May 1973
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This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers. Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - as supplies permit - from the
Air Pollution Technical Information Center, Environmental Protection
Agency, Research Triangle Park, North Carolina 27711, or from the
National Technical Information Service, 5285 Port Royal Road, Springfield,
Virginia 22151.
This report was furnished to the Environmental Protection Agency by the
Argonne National Laboratory. Argonne, Illinois 60439, in fulfillment of
Interagency Agreement No. EPA-IAG-0159(D) . The contents of this report
are reproduced herein as received from the Argonne National Laboratory.
The opinions, findings, and conclusions expressed are those of the author
and not necessarily those of the Environmental Protection Agency. Mention
of company or product names is not to be considered as an endorsement
by the Environmental Protection Agency.
Publication No. EPA-450/3-74-028-a
11
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TABLE OF CONTENTS
ABSTRACT Vi
1.0 INTRODUCTION 1
2.0 SIGNIFICANCE OF SOURCE-CLUSTERING IN THE CHICAGO AREA ... 5
3.0 PERMIT SYSTEMS AS A MECHANISM TO MONITOR
SOURCE-CLUSTERING 12
4.0 ZONING AS A MECHANISM FOR CONTROLLING THE
DEVELOPMENT OF SOURCE CLUSTERS 18
5.0 LAND USE PLANNING AS A MECHANISM TO CONTROL
SOURCE-CLUSTERING 26
6.0 CONCLUSIONS AND RECOMMENDATIONS 35
111
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LIST OF FIGURES
No. Title Page
2.1 Isopleths of sulfur dioxide due to heavy residential/
commercial emissions. 6
2.2 Isopleths of sulfur dioxide due to steel mill emissions. . 8
2.3 Isopleths of sulfur dioxide due to petroleum
plant emissions. 9
2.4 Isopleths of carbon monoxide emission density 11
3.1 Mean suspended particulate emissions (Ibs/hr) vs.
standard deviations by two-digit SIC classification
with Illinois source control regulations applied. ... 16
4.1 Isopleths of suspended particulates* using emission-
density limits (EDL) for heavy industry. 20
4.2 Frequency of suspended particulate emission
densities for heavy industry. 21
4.3 Frequency of suspended particulate emission
densities for light industry. 22
4.4 Comparison of emission reductions for zoning
regulations with present Illinois emission controls. . . 24
5.1 Frequency of suspended particulate emission densities
for total manufacturing with Illinois source control
regulations applied. 28
5.2 Isopleths of suspended particulates* using mean
emission-density estimates for manufacturing land. . . 29
5.3 Isopleths of suspended particulates with Illinois
source control regulations applied. 30
5.4 Frequency of suspended particulate fuel combustion
emission density with Illinois source control
regulations applied. 32
5.5 Frequency of suspended particulate process emission
density with Illinois source control regulations
applied. 33
IV
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LIST OF TABLES
No. Title
6.1 STUDY SUMMARY 39
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ABSTRACT
In order to meet and maintain ambient air quality standards called for
in the Clean Air Act of 1970, specifically, "nondegradation" of air quality
presently better than the national standards, it was felt that a study was
needed of alternative means for the control of high emission source-
clustering.
Three such policies are considered in this study: air pollution impact
statements; zoning control in two forms, permitted-use zoning and emission-
density- limited zoning; and the prediction of air pollution impacts of compre-
hensive regional land use plans. This report also considers the source-
clustering problem in the Chicago area, specifically in relation to the effec-
tiveness of the three investigated control strategies.
VI
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1.0 INTRODUCTION
For the past two years, Argonne National Laboratory's Center for
Environmental Studies, under the sponsorship of the Land Use Planning Branch
of the Office of Air Quality Planning and Standards, has carried out studies
to investigate the relationship of air quality to land use guidance and
control practices. These studies have used the Chicago metropolitan region
as a demonstration area to test the effectiveness of alternative land-use
environmental controls. The need for such research stems from the require-
ment that the federal Environmental Protection Agency ensure the attainment
and maintenance of national ambient air quality standards. In addition, the
Clean Air Act of 1970 has inspired controversy around questions related to
nondegradation of ambient air quality presently better than the national
standards.
The exact meaning of "nondegradation" is a question of considerable
controversy. In its literal, most narrow interpretation, it could prohibit
any increase in emissions (and, therefore, all economic growth) within a
region or state. On the other extreme, "nondegradation" could be interpreted
as merely indicating that secondary air quality standards must be maintained
throughout the state. A specific definition was required in the Argonne
National Laboratory study in order to develop the appropriate land use and
air .quality control strategies to be evaluated and to focus the policy
analysis. In this study, significant deterioration of air quality was
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defined to have occurred when in any area of an air quality control region,
a concentration or cluster of high emission sources had developed. An inves-
tigation of a relevant land-use/air-quality control policy would then consist
of an evaluation of policies designed to prohibit or discourage the creation
of such source clusters.
This interpretation was considered to be a compromise between the
extremes of definitions, implying either no economic growth or simply the
meeting of air quality standards. If the present air quality standards have
been met and maintained, the next stage of control in ensuring that air
quality degradation did not occur in presently clean areas was deemed to be
the implementation of policies aimed at discouraging potentially dangerous
high emission source clusters from forming. In this program, three such
control policies have been investigated. These are:
1) Air quality impact statements for large emitters prone to
locate in source clusters.
This strategy would be directed toward reducing the loca-
tional concentrations of large industrial sources. The major
questions to be answered in the implementation of such a control
strategy are: What criteria are appropriate for describing the
conditions under which an impact statement should be required?
Who should be required to make such impact statements? How can
emitters be classified to make such a system of controls admin-
istratively feasible?
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2) Zoning regulations designed to prohibit the creation of source
clusters.
Two forms of zoning were investigated: Permitted-use zoning,
which excludes activities from specified areas; and emission-density-
limited zoning, which prohibits sources from emitting over a
certain level of emissions per acre. Because permitted-use zoning
is already wide-spread in the United States, the major question
in evaluating its effectiveness as an anti-source-clustering policy
is whether the air quality effects of alternative zoning policies
can be accurately projected. The very basis of emission-density-
limited zoning is aimed at the prohibition of source clusters;
in this case, the significant questions are: Can emission-density
limits be established to ensure that the imposition of such a
regulation will guarantee that air quality standards will be met?
Secondly, how does emission-density-lijnited zoning compare with
the more orthodox source control regulations now in effect?
3) The use of comprehensive land-use planning as a long-range method
of predicting and avoiding source clusters.
The use of comprehensive land-use planning to guide the
developmental practices in a region along environmentally accept-
able lines has generated considerable interest in the past few
years. A critical question to be examined is whether the air
quality impacts of land-use plans can be accurately predicted
using information commonly generated in the planning process.
The remainder of this summary report will discuss the source-clustering
problem in the Chicago area, and summarize briefly the findings of our
investigations with respect to the relative effectiveness of these three
3
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policy options. Volume II of this report discusses in detail the develop-
ment of land-use-based emission factors and their use in estimating air
quality from land-use plans. Volume III evaluates the effectiveness of
alternative land-use control policies available to planners and compares
this approach with the traditional technology-oriented, point-source controls
currently used in air quality enforcement programs.
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2.0 SIGNIFICANCE OF SOURCE CLUSTERING
IN THE CHICAGO AREA
The first step in the investigation of anti-clustering policies was
to describe the type of source clusters occurring in the Chicago area and
to evaluate the extent of such clustering phenomena. In evaluating con-
trol policies designed to discourage source clusters, three characteris-
tics are of major importance: their present size and extent, the probabili-
ty of the economic growth of such clusters, and the air quality effects.
In the Chicago area, a number of high concentrations of emitters were
identified. On the near south side of Chicago, a concentration of coal-
fired, space-heating apartments created a severe problem particularly
during the colder part of the heating season. Figure 2.1 shows the air
quality concentrations of sulfur dioxide (as represented by "isopleths" or
lines of constant concentrations) due to these sources. The severe effects
of this residential clustering of coal-fired space heating has led the State
of Illinois to propose a ban on the use of coal for space heating within the
Chicago Metropolitan Air Quality Control Region cannot meet the air
quality standards for particulates by 1975. The long-run significance of
such residential space-heating source clusters is somewhat diminished due
to the fact that from the mid-1960s to the present time, there has been a
significant shift in the use of fuels for residential space heating from
coal to gas and oil in the Chicago area. It has been hypothesized that
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AM, No-.'. No. 1M-22/
Figure 2.1. Isopleths of sulfur dioxide* due
to heavy residential/commercial
emissions.
*(yg/m3 - arithmetic mean)
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this market trend will alleviate the requirement for specific legisla-
tion to control this form of source clustering. An investigation is now
underway as part of a joint research project of The University of Chicago
and Argonne National Laboratory to determine if the present trends in
residential fuel markets will indeed be sufficient to discourage the
development of this form of source clustering in the future.
Significant industrial concentrations of polluters were also found
within the Chicago region. The economic factors that cause such indus-
trial agglomeration are still far from well understood, but the air
quality effects of such concentrations are evident. In Figures 2.2 and
2.3, the respective pollution concentration caused by the refining and
steel industries in the Chicago area are shown. In the case of the steel
complex, the air quality effects of this concentration are superimposed
upon the effects of the residential space heating concentration mentioned
previously. Due to the high level of development of land in the areas
adjacent to the steel complex, it is quite unlikely that the source
cluster will continue to grow. This is not the case, however, with
respect to the refining industry. It is projected that refining and
chemical products will enjoy a 50% growth rate over the next 7-10 years
and that a majority of this growth will occur primarily in one of the
seven counties comprising the Chicago Air Quality Control Region.
The significance of the third type of source clusterthe concentra-
tion of commercial activities within the central business district of
Chicagolies more in its induced effects of concentrating an enormous
amount of vehicular traffic in a small area. As yet, no air quality
estimates have been made using calibrated air quality models within the
region. However, the emission density map for carbon monoxide in
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Figure 2.2. Isopleths of sulfur dioxide* due
to steel mill emissions.
*(yg/m3 - arithmetic mean)
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Figure 2.3. Isopleths of sulfur dioxide* due
to petroleum plant emissions.
* (Mg/m - arithmetic mean)
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Figure 2.4 indicates in a general way the severity of the induced air
quality effects of this intense concentration of commercial and recrea-
tional activities. Based upon Chicago Area Transportation Study estimates
of the distribution of growth of vehicular miles in the Chicago area, the
central business district has already reached a near-saturation level of
peak-hour traffic. Thus, it may be concluded that although this situation
constitutes a serious source-clustering problem in Chicago at the present
time, the problem is not likely to be aggravated in already large and
well-developed urban areas with centralized business districts. For cities
whose commercial districts are still in an early stage of development, this
assumption, of course, will not be valid.
10
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Figure 2.4. Isopleths of carbon monoxide emission density.
(tons/day/square jnile)
11
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3.0 PERMIT SYSTEMS AS A MECHANISM TO MONITOR SOURCE CLUSTERING
Present permit practices are directed toward one of two objectives:
the evaluation of the application of control technology to the operation
of pollution-producing equipment in the case of most state permit systems;
or the evaluation of the total environmental impact of a single, highly
significant source such as a power plant. Neither of these objectives
encompasses a mechanism to assess or discourage the creation of a source
cluster. Each is essentially directed toward the evaluation of the
control and emissions of a single source. It was the objective of this
phase of our investigation to assess the practicability of extending the
concepts of permits or environmental impact statements so as to define a
permit mechanism directed at the phenomenon of source clustering and its
air quality consequences.
Figures 2.2 and 2.3 of the previous section indicate graphically that,
although such sources as petroleum plants or steel mills do not singly
have the impact that fossil fuel power plants have in terms of emissions,
they have a tendency to cluster in geographically dense concentrations.
Thus, it may be desirable to monitor a wider range of the environmental
impact of locational decisions in such industries than is envisioned in
present state or federal permit systems. In effect, this type of environ-
mental land use control policy creates a "permit to locate" in addition
to the present "permit to operate" and "permit to construct" that are the
12
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normal components of state and federal permit systems. Under such a
monitoring system, the states would have power to prohibit firms from
locating in certain areas. Permits-to-locate could be withheld not only
because of the projected effects of emissions from the sources applying
for such permits, but also because of present and projected ambient con-
centrations of pollutants within the immediate area.
The major administrative difficulty in implementing such a monitoring
and controlling mechanism over the growth of stationary source emission
clusters is to define the conditions under which such a permit-to-locate
should be required. Obviously, many sources of air pollution will not be
significant enough to materially affect air quality concentrations. More
importantly, requiring a review of each industry with a pollution-produc-
ing source in order to evaluate the areawide air quality effects of its
decision to locate would put a large administrative burden on the state.
Two mechanisms by which certain industries could be selectively required
to prepare and to submit such a permit-to-locate may be hypothesized:
(a) The state could be divided into air quality districts much
smaller than the present air quality control regions and permit require-
ments could be defined such that, if any given district has a total
emission level exceeding some standard, all new firms having pollution-
producing equipment and wishing to locate there be required to obtain a
permit-to-locate. Alternatively, the air quality in each such sector
could be measured and projected using the dispersion models, and a set
of air pollution concentration standards somewhat below the present
secondary standards could be defined. When projections indicate such
air pollution levels will be reached within five or so years, any new
polluters wishing to locate in the region would have to obtain a
13
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permit-to-locate. In all probability, such permits would require infor-
mation regarding area source emissions and air quality that only the
state or local environmental protection agencies would have available.
Therefore, it would be anticipated that the development of such a
permit-to-locate would be a joint effort of the local air quality control
agency and the industry in question. Under such a system, any industry
desiring to locate in the area of the petroleum and steel industrial com-
plexes shown in Figures 2.2 and 2.3 would be required, in conjunction
with the local air pollution officials, to assess the total areawide
effects of its location.
(b) A ranking of pollution sources according to some standard indus-
trial classification scheme could be made and those industries in the
highest ranking classifications could be required to obtain a permit-to-
locate. This technique would reduce the required number of permits-to-
locate on the basis of the average emission levels of polluters in that
industrial category. The major problem with this approach is in estimat-
ing the average emissions based upon any of the presently defined indus-
trial classifications. Attempts were made in the Argonne study to
classify average particulate and sulfur dioxide emissions according to
2-digit standard industrial classification categories. The difficulty
in using this classification scheme in identifying requirements for a
permit-to-locate is the large variance of emissions for polluters within
a given industrial classification sector. For example, even though the
average emissions from the primary metal industriesSIC 33are about
equal to the average emissions of the chemical and allied industrial
14
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sector&IC 28(based on analysis of the Chicago emission inventory), the
variation in emissions in the chemical sector is 25-30% higher than the
variation in the primary metals industry. Although their average emissions
are approximately equal, the environmental risk of allowing a petroleum
plant to locate within a region is greater than of allowing a primary
metal plant to locate there; there is a greater possibility that the given
petroleum plant will have much higher emissions than the industrial average.
Because of this variance problem in employing standard industrial
classifications to rank emissions, a further investigation was carried out
to rank industries both by their average emissions and by the standard
deviation associated with these average estimates as illustrated in
Figure 3.1. It has been assumed that the Illinois source regulations are
in effect. Figure 3.1 also indicates that, in terms of pollution poten-
tial as measured by the mean and standard deviation of particulate emis-
sions, six industries could be singled out as having emissions large
enough to warrant a more extensive evaluation of the air quality effects
of their locational decisions. These are the following:
1. food and kindred products (SIC 20)
2. paper and allied industries (SIC 26)
3. chemical and allied industries (SIC 28)
4. petroleum and coal industries (SIC 29)
5. the stone, clay, and glass industry (SIC 32)
6. the primary metals industry (SIC 33)
In the Chicago area, it has already been demonstrated that the primary
metals and chemical and allied industrial complexes in the southern part
of the Chicago Air Quality Control Region do represent significant dangers
by reason of their source clustering characteristics.
15
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30r ,! j r -
25
20
UJ
*
10
33o
26 9
370
36
wen
_ I I I I I I I
0 5 10 15 20 25 30 35 40
STANDARD DEVIATION
Figure 3.1. Mean suspended particulate emissions (Ibs/hr)
vs. standard deviations by two-digit SIC classi-
fication with Illinois source control regulations
applied.
16
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Naturally, the industrial mix and location of industries within the
Chicago area will be different from those found in other areas of the
country. To draw more valid conclusions as to the practicability and
desirability of encouraging states to broaden the concepts of permits
in monitoring the growth of source clusters, it would be desirable to
assess the existence of such high emission source clusters in other
regions of the country, using the national emission data file developed
by the Environmental Protection Agency.
17
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4.0 ZONING AS A MECHANISM FOR CONTROLLING
THE DEVELOPMENT OF SOURCE CLUSTERS
One of the objectives of the Argonne National Laboratory study was
to make an investigation of both permitted-use zoning and emission-
density- limited zoning as alternative mechanisms for environmental land
use control. It was found that the classification scheme used in most
of the normal permitted-use zoning regulations was too coarse in struc-
ture, particularly in the areas of heavy and light industrial zoning
classes, to provide an effective means of measuring change in air quality
due to changes in standard zoning regulations. Subsequent investigations
concentrated, therefore, on the emission-density-limited zoning.
The central concept behind emission-density-limited zoning is that
the density of emissions (i.e., the pounds of emissions per square mile
or acre per unit time) should be the basis for regulation rather than just
the level of emissions of given sources. Emission-density regulation, by
definition, would restrict the growth of source clusters, because it
explicitly takes into account the density of emission sources. Emission-
density limits preclude large emitters from purchasing relatively small
amounts of land and locating in areas of high emission density.
18
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Two major questions to be asked with regard to emission-density-
limited zoning are: Can emission-density limits be established to ensure
that the imposition of such a regulation will guarantee that air quality
standards will be met? Secondly, how does emission-density-limited zoning
compare with the more orthodox source control regulations now in effect.
Using the Chicago emission inventory, several alternative forms of an
emission-density-limited zoning regulation were simulated in order to shed
light on these questions. Figure 4.1 shows one such simulation; in it
emission-density-limited zoning was defined for three categories of polluters.
Heavy industrial polluters were prohibited from emitting more than 3.0 tons
of particulates per day per square mile; light industrial polluters were
prohibited from emitting more than 1.4 tons of particulates per day per
square mile; and heavy residential/commercial sources of pollution were
prohibited from emitting more than .5 tons per day per square mile. (In
these simulations, light industry was defined to be any industry in the
Standard Industrial Classifications 20-25 and 34-39. Heavy industrial clas-
sifications were those SIC 26-33.) The air quality effects of this regula-
tion are shown in the isopleth map. It should be noted that applying this
regulation to uncontrolled emissions in the Chicago area resulted in an
estimation of air quality that meets the national ambient air quality
standards. Suggested methods and criteria for selecting the emission-density
limits are described in Volume III of this report.
In order to evaluate the distribution of the emission reductions
required by this regulation, a frequency diagram was generated; it indicates
the distribution of sources categorized according to their emission densities.
Figures 4.2 and 4.3 show these frequency plots for both heavy and light
19
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WILL COUNTY
Emission Density Limit (EDL) for:
HI /*
Heavy Industry (EDL ) = .39 (Ib/lir/ac) - 3.0 (T/D/mi )
Light Industry (EDLLI) = .18 (Ib/hr/ac) = 1.4 (T/D/mi2)
LAKE COUNTY
Figure 4.1. Isopleths of suspended particulates* using
emission-density limits (EDL) for heavy industry.
o
*(ngm/m - annual arithmetic mean - uncalibrated model)
20
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EDL = .39 (Lbs/Hr/Acre)
= 3.0 (T/D/Mi2) ,40
140
130
120
no
100
so
;"! or,
<_> Ou
z:
ii i
= 70
o
cr 60
u_
50
40
30
20
10
PERCENTILE = 40%
120
-
-
-
-
-
-
-
soo
80
60
40
20
0
MEAN = 47.6 (Lbs/Hr/Acre)
o
1 = 371 (T/D/Mi2)
i
l
1
l
l
i
1 i
! ! 1 1
10 . 100 1000 10.000
HEAVY INDISTRY (HI)- SIC 26-33
TOTAL NU flBER OF SOURCES 255
1 III i ! : 1 1 , -.
0 ?345fi7RQint
EMISSION DENSITY, Lbs/Hr/Acre
Figure 4.2. Frequency of suspended particulate
emission densities for heavy industry.
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I20f-
to
110
100
90
80
S 7°
g 60
S 50
ex
^ 40
30
20
1C
0
L.UI.
"'
1
- .10 VLUS/ ni / Miie;
= 1.4 (T/D/Mi2) 80
PERCENTILE = 29%
60
40
20
LIG
MtAN = ci.d. lLD3/Hr/Acrs)
= 212 (T/D/Mi2)
i ' 1
10 !DO iOOO 10,000
HT INDUSTRY (LI) - SIC 20-25
34-39
TOTAL NUMBER OF SOURCES 203
-
. > |
i i i i ti i j" i " i ^
?345fi78qmt
EMISSION DENSITY, Lbs/Hr/Acre
Figure 4.3. Frequency of suspended particulate
emission densities for light industry.
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industrial source classifications. Due to the significant skewness of these
distributions, only about 60% of the heavy industrial emitters were required
to reduce their emissions (based upon the three tons per day per square
mile emissions-density regulation). In the case of light industrial sources,
approximately 70% were affected by the 1.4 tons per day per square mile
limit for emission density.
Because the emission-density zoning regulations favor those industries
that are more land intensive, it~is to be expected that the distribution of
the required source reductions under the zoning regulation would be signifi-
cantly altered from the present distribution of emission reduction under the
Illinois source control regulations. The required percentage reduction for
those industries in each Standard Industrial Classification category were
calculated under the conditions of both the emission-density-limited zoning
regulation and the present Illinois source control regulations. Figure 4.4
indicates the results of this analysis. It is rather surprising that the
percentage reductions required by the present Illinois law should approxi-
mate so closely the required reductions under the zoning regulation.
In summarizing the findings of this analysis with respect to the appli-
cability of emission-density-limited zoning, we should make three major
points. The first is that (using the Chicago emission inventory and
standard dispersion modeling techniques) a zoning regulation or set of regu-
lations can be formulated to meet the national ambient air quality standards
for suspended particulate matter. Second, the results presented in
Volume III of the application of a cost model to both types of control in
the Chicago region indicate that in terms of immediate costs and effectives
ness, the emission-density-limited zoning seems to compare favorably with
the present structure of emission control regulations. The third point, and
23
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I Reduction - Point-Source Control Regulation
o Reduction - linission-Dcnsitv-Li^it.ed J!o:iin" I emulation
Figure 4.4. Comparison of emission reductions for
zoning regulations with present Illinois
emission controls.
-------
perhaps the most significant in terms of the control of the development of
emission source clusters, is that emission-density zoning provides not only
a mechanism for attaining air quality standards at the present time, but
also ensures that source clusters will not develop in the future.
25
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5.0 PROJECTIONS OF AIR QUALITY VIA COMPREHENSIVE PLANNING
The use of comprehensive land use planning as a mechanism to avoid some
of the deleterious environmental consequences of economic development has
come under a great deal of discussion in the past few years. The attractive-
ness of comprehensive land use planning in controlling the long-range environ-
mental quality of a region steins from the fact that entering environmental
considerations into the planning process itself, represents the least disrup-
tive method of maintaining environmental quality, while still allowing for
sufficient economic growth to ensure the overall viability of the region.
The central question with regard to the use of this method as a
mechanism to ensure that dangerously high emission source clustering does
not occur in the region is whether the air quality effect of future source
clustering phenomena could be accurately represented using projections that
are likely to be available in comprehensive land use plans. The projection
of ambient air quality depends upon the ability to project the future loca-
tions and levels of activity of economic sectors and, using these land use
projections, to estimate future emission-density patterns. The ability to
make such estimates ultimately resolves itself into a problem of developing
and projecting land-use-based emission factors. Using the Chicago Emission
Inventory, a number of alternative strategies were employed to generate
such factors. Subsequently, these factors were applied to presently avail-
able Chicago land use data to evaluate whether the use of these factors
26
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could accurately reproduce estimates of air quality conditions in the
Chicago area. Once such factors have been catalogued as a function of plan-
ning parameters and their utility tested, they can be applied to proposed
land use plans for purposes of evaluating their air quality impacts.
To generate land-use-based emission factors that are compatible with
information presently available in comprehensive land use plans, the most
direct procedure consists in estimating the present average emission den-
sity for each of the major economic sectors represented in the present
Chicago Emission Inventory. These sectors can be classified into either
zoning or standard industrial classifications. Figure 5.1 shows the emis-
sion density distribution of industrial class sources within the Chicago
area. Not only is the standard deviation of this distribution quite high
in relation to its average, but the skewness of the distribution causes
2
significant estimation problems if the mean of 9.0 T/D/mi is used as
an emission density factor in projecting future air quality. Figure 5.2
shows the calculated air quality for suspended particulates as derived by
2
applying a 9.0 T/D/mi emission - density factor to the .present indus-
trial land use pattern in the City of Chicago. Figure 5.3 shows the sus-
pended particulate air quality estimates based directly upon the applica-
tion of standard emission factors to the Chicago Emission Inventory. The
use of the average emission-density factor for industrial lands did produce
average air quality estimates that approximated the average air quality over
the entire region. However, due to a bias in estimating this factor, pockets
of very high concentrations seem to appear. Thus, air quality estimates
based on average emission-density factors, as opposed to estimates based on
actual point-source emissions, would be unrepresentative. If these air
27
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to
oo
280
280
260
240
220
200
180
o |60
ii i
§140
LU
2: 120
100
80
60
40
20
0
-
-
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-
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-
-
240
200
160
120
80
40
0
MEAN = 1.17 (Lbs/Hr/Acre)
1 - d n tTir\'ti'?.\
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\ ST. DEV. = 5.03
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^ T ,
till 1 I 1 ! ! >
2 4 6 8 10 1.2 1.4 16 1.8 20 *
EMISSION DENSITY, Lbs/Hr/Acre
Figure 5.1. Frequency of suspended particulate emission densities for
total manufacturing with Illinois source control regulations
applied.
-------
Figure 5.2 Isopleths of suspended particulates* using mean emission-density
estimates for manufacturing land.
(mean =9.0 T/D/MT = 1.17 Ib/hr/acre)
(*yg/m - annual geometric mean)
29
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COOK COUNTY
DuPAGE
COUNTY
WILL
COUNTY
Figure 5.3. Isopleths of suspended particulates* with
Illinois source control regulations applied.
*(yg/m3 annual geometric mean)
30
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quality estimates were used in ranking alternative land use plans or in
trying to identify future potential source clusters in the Chicago area, one
might conclude that air quality standards will not be met under the present
conditions of Chicago land use patterns and air quality regulations.
This does not mean that the projections of air quality using these
estimators are not a useful tool in ranking the air quality effects of alter-
native land use plans. Due to the bias of the land use emission-density
factor estimates, those plans containing a larger percentage of industrial
zoned land will, in all probability, be ranked as being likely to produce
more significant degradation of air quality than might otherwise be. It is
therefore our recommendation that, in using the mean estimators for land-use-
based emission densities, some method be developed to specifically take into
account the skewness and variance of these distributions in projecting future
air quality.
A major source of the variance in the emission factor estimates is
caused by the industrial process sources. In Figures 5.4 and 5.5, respec-
tively, the present distribution of emission densities for fuel combustion
and process sources are shown. An examination of the standard deviation of
these distributions compared with the standard deviation of the frequency
distribution of the emission densities for the industrial sector as a whole
indicates that almost the entire variance in the emission-.density estimate
is due to the variance of emissions in process sources. Thus, it can be
anticipated that, if present land use industrial projections could be disag-
gregated into process and fuel combustion sources, the projected air quality
estimates would be somewhat improved. This does not alleviate the need,
however, to specifically account for the wide variation in emission densities
31
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MEAN = .048 (Lbs/Hr/Acre)
N)
260
220
200
180
>. !50
S 120
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u.
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§ 140
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100
80
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280
240
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~
ISO
MEAN =1.12 {Lbs/Hr/Acre)
|' =8.7 (T/D/^i2)
i ST. DEV. = 5.02
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f
i20
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i
j
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III, ! 1 j
EMISSION DENSITY, Lbs/Hr/Acre
Figure 5.5. Frequency of suspended particulate process emission
density with Illinois source control regulations
applied.
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for industrial process sources. Volume II of this report details some of the
methods used to.explain this variance, using planning parameters such as
standard zoning and industrial classification systems, employment, and land
use.
34
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6.0 CONCLUSIONS AND RECOMMENDATIONS
In reviewing the applicability of the alternative methods of ensuring
that source clusterings do not develop as a serious threat to air quality,
it must be recognized that the evaluation made thus far has been carried out
independently of any considerations of the administrative difficulty in imple-
menting the proposed strategies. The results of this investigation have
indicated, however, that these strategies do represent in some cases viable
alternatives or adjuncts to the present structure of air quality control
regulations.
It should also be recognized that the applicability and significance of
these strategies depends upon the present priority of land use and environ-
mental control programs. If the future clustering of large industrial
emission sources presents the only significant air quality degradation prob-
lem, the use of permit systems to reduce source clustering would seem to be
the most easily implemented strategy. On the other hand, if a broad range
of land use developmental practices constitutes the cause of emission source
clustering in large metropolitan areas, more comprehensive approaches such
as emission-density-limited zoning or the use of comprehensive planning in
avoiding such practices will be necessary.
The following specific conclusions, substantiated in Volumes II and III
of this report, have been drawn from this study.
35
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SUMMARY OF CONCLUSIONS
1. Source clustering in the Chicago region is a major problem, even
with control technology applied, and will pose the major threat to
air quality maintenance in the long run.
2. The major significant source clusters will be industrial process or
induced traffic due to concentrations of intense residential/
commercial land use. Residential/commercial fuel combustion will
not be a problem, assuming the availability of clean fuels.
3. Anti-source clustering policies and the long-run deterioration of
currently clean air zones have not been adequately addressed on
local, state, or federal levels. Options for anti-clustering
control include:
a. An impact statement or permit-to-locate system;
b. A zoning control system;
c. A comprehensive planning process that includes
air quality impact analysis.
4. An impact statement policy can be based on the two-digit SIC classi-
fication.
5. Emission-density zoning is an effective long-range control and
is no more costly than point-source control, assuming a stable
zoning process. In addition, deterioration in air quality is
predictable and controlled virtually by the definition of the
density limitation.
6. Comprehensive planning as a control mechanism depends on:
(1) the stability of the plan over time; (2) the ability of
public administrators to implement the plan; and (3) the ability
of planners to forecast the air quality effects of land use
36
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decisions and policies and to rank land use plans. The
latter element of the process has been tested extensively in
this study with only sporadically successful results to date.
The major problem concerns the wide variance and skewness in
emission-density distribution for manufacturing land use.
Because of the nature of these distributions, severe distortions
in air quality representations occur when mean estimates are
employed.
The following recommendations with regard to long-run maintenance of
air quality standards are made as a result of this study.
SIMtARY OF REO3MMENDATIONS
1. The policies for maintaining air quality at standards should
be defined in terms of controls aimed at the discouraging
high emission-density source clusters. Therefore, the EPA
should conduct a national study of significant source clusters
in major metropolitan areas.
2. It is recommended that one or more of the following policies
be encouraged by the EPA for state implementation as an
anti-source clustering strategy:
a. An impact statement or permit-to-locate system;
b. A zoning control system;
c. A comprehensive planning process that includes air
quality impact analysis.
3. If this national policy employs impact statements or "permit-
to-locate" systems as control mechanisms, a determination of
appropriate criteria for the application of these policies
and the development of administrative procedures are required.
37
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4. If the national policy employs emission-density-limited zoning,
a national study of levels of effective density limits and costs
is required, along with the admininstrative methods of implementing
such a policy. Model emission-density-limited zoning regulations
should be developed as a result of this study.
5. If the national policy employs comprehensive planning, new methods
for ranking land use plans that include a realistic appraisal
of the risks of air quality deterioration are required. Before a
standardized air quality analysis procedure can be adopted by the
planning community, methods for explaining the variance in emission
densities, or otherwise accounting for this variance by simulation
procedures, is required.
The following Table 6.1 summarizes in detail the results of this study,.
as described in Volumes I, II, and III of this report.
38
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10
Table 6.1. STUDY SUMMARY
ANTI-SOURCE-
CLUSTERING POLICY
LOCATIONAL PERMITS
AM)
IMPACT STATEMENTS
ZONING
PERMITTED- USE
EMISSION- DENSITY LIMITED
CCMPREHENSTVE
PLANNING
PROCESS
ANALYTICAL
METHODS
Source -clustering
identification using
dispersion modeling.
Analysis of variance
in industrial emissions
by 2-dLgit SIC code.
Analysis of variance
in emission densities
by zoning class.
Use of emission-density
cstijnai.es in represent-
ing air quality.
Cost-el fectivcness
comparison of point-
source control regula-
tions and emission-
density-limited zoning
as approaches to
region.-.l air quality
maintenance and control.
Analysis of variance
in emission densities
by land use class and
2-digit SIC code.
Use of emission-density
estimates in represent-
ing air quality.
Product-moment correla-
tion, simple and
multiple regression.
RESULTS AND
CONCLUSIONS
Large variance occurs
within 2-digit SIC groups.
Mean and standard devia-
tion of emissions can be
used to rank industrial
emissions by 2-digit
SIC code.
Emission densities by
"traditional" permitted-
use zoning do vary signif-
icantly, but do not
provide adequate air
quality representation.
Bnission-density-
linitcd zoning is effec-
tive in controlling and
maintaining air quality.
Further, the control cost
to current sources does
not significantly increase
over point- source control
regulations now in
existence.
Major problems occur
with wide variance in
emission densities caus-
ing distortions when
predicting air quality
from land use.
Incomplete data avail-
able, particularly for
predicting industrial
process emissions.
Dwelling unit density or
floor area ratios proved
useful in predicting
energy use from resi-
dential and conroercial
land use.
REMAINING
PROBLEM AREAS
* Criteria must be estab-
lished for requiring
locational permits or
impact statements.
Legal activity and
administrative
procedures are required.
Acceptance of emission-
density-limited zoning
as a viable concept for
air pollution control.
Administrative arrange-
ments between air pol-
lution control
officials and zoning
administrators .
Interface between plan-
ning agencies and air
pollution control
agencies ill-defined.
Determine variables
useful in predicting
process emissions.
Test utility of employ-
ment and other inten-
sity measures in pre-
dicting air quality
via dispersion modeling.
RESULTANT
FEDERAL POLICIES
Define areas of critical
concern.
Guidelines for use of
locational permits and
impact statements.
Create administrative
mechanisms for imple-
menting source-clus-
tering control via
locational pcnnits or
impact statements.
Model zoning ordinances.
Guidelines for includ-
ing air quality in the
zoning process.
Define procedures for
analysis of air quality
impacts of land use and
urban development.
Specify required data
collection, publication.
and use procedures.
Specify air pollution
planning agency working
relationships.
FURTHER
STUDIES NEEDED
National asscssrr.ant of
of source-clustering
problem.
Evaluation of alterna-
tive administrative
procedures for imple-
menting locational
permits or impact
statements as methods
of source-clustering
control.
National study of
levels of cost-
effective emission-
density lijnits.
Develop and compare
model emission-
density- limited
zoning ordinances
for major metropol-
itan areas.
Further tests of
predicting air
quality effects of
land use, using
intensity of land
use measures.
Develop reasonable
growth projection
methods and test
their ability to
predict air quality
deterioration.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-74-028-a
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Air-Pollution/Land Use Planning Project
Volume I. Selected Land Use Control Policies for Air
Quality Management
5. REPORT DATE
May 1973
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
A.S. Kennedy, K.G. Croke, I.E. Baldwin and
R.L. Reisenweber
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Argonne National Laboratory
Energy and Environmental Studies Division
9700 South Cass Avenue
Argonne, Illinois 60439
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
EPA-IAG-0159(D)
12. SPONSORING AGENCY NAME AND ADDRESS
Transportation and Land Use Planning Branch
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
In order to meet and maintain ambient air quality standards called for in
the Clean Air Act of 1970, specifically, "nondegradation" of air quality
presently better than the national standards, it was felt that a study was
needed of alternative means for the control of high emission source-clustering.
Three such policies are considered in this study: air pollution impact
statements; zoning control in two forms, permitted-use zoning and emission-
density-limited zoning; and the prediction of air pollution impacts of compre-
hensive regional land use plans. This report also considers the source-clustering
problem in the Chicago area, specifically in relation to the effectiveness of
the three investigated control strategies.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Land Use
Planning and Zoning
Local Government
Air Pollution Control Agencies
Area Emission Allocations
3. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (ThisReport)
21. NO. OF PAGES
20. SECURITY CLASS (Thispage)
22. PRICE
EPA Form 2220-1 (9-73)
40
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